Ynot v IAC
FACTS
142 SCRA 699 Political Law Bill of Rights Due Process Due Process in Whether or
Educational Institutions
In 1984, Diosdado Guzman and two others complained that the National University
(NU) barred them from enrolling in the said university. NU argued that their failure to
enroll was due to the students fault. It was alleged that Guzman et al spearheaded
illegal mass actions within the university premises; that such mass actions were
violative of school policies; that due to their mass actions, Guzman et al incurred bad
grades; that Guzman et al hated NU anyway so why should they be allowed to enroll;
that it is in the best interest of both parties for the students not to be enrolled.
Petitioners Diosdado Guzman, Ulysses Urbiztondo and Ariel Ramacula, students of
respondent National University, have come to this Court to seek relief from what they
describe as their school's "continued and persistent refusal to allow them to enrol." In
their petition "for extraordinary legal and equitable remedies with prayer for
preliminary mandatory injunction" dated August 7, 1984, they alleged that they were
denied due process due to the fact that they were active participants in peaceful
mass actions within the premises of the University.
The respondents on the other hand claimed that the petitioners failure to enroll for
the first semester of the school year 1984-1985 is due to their own fault and not
because of their alleged exercise of their constitutional and human rights. That as
regards to Guzman, his academic showing was poor due to his activities in leading
boycotts of classes. That Guzman is facing criminal charges for malicious mischief
before the Metropolitan Trial Court of Manila in connection with the destruction of
properties of respondent University. The petitioners have failures in their records,
and are not of good scholastic standing.
ISSUE RULING / HELD
No. Guzman et al were deprived of due process. In the first place, NU never showed which
not National school policies or duly published rules did Guzman et al violate upon which they may be
University expelled from. NU failed to show that it conducted any sort of proceedings (not necessarily a
may not admit trial type one) to determine Guzman et als liability or alleged participation in the said mass
the Diosdado actions.
Guzman et al
in the case at Under the Education Act of 1982, Guzman et al, as students, have the right among others to
bar. freely choose their field of study subject to existing curricula and to continue their course therein
up to graduation, except in case of academic deficiency, or violation of disciplinary regulations.
Guzman et al were being denied this right, or being disciplined, without due process, in violation
of the Manual of Regulations for Private Schools which provides that no penalty shall be
imposed upon any student except for cause as defined in the Manual and/or in the school rules
and regulations as duly promulgated and only after due investigation shall have been
conducted.
Therefore, in effect, NU, by barring the enrollment of Guzman et al imposed sanction upon the
students without due investigation such act is illegal.
The Supreme Court also emphasized the minimum standards which must be met to satisfy the
demands of procedural due process; and these are:
1. That the students must be informed in writing of the nature and cause of any accusation
against them;
2. That they shall have the right to answer the charges against them, with the assistance of
counsel, if desired;
3. That they shall be informed of the evidence against them;
4. That they shall have the right to adduce evidence in their own behalf; and
5. That the evidence must be duly considered by the investigating committee or official
designated by the school authorities to hear and decide the case.